Privacy Policy

Please read this Privacy Notice carefully. It provides important information about your personal information. It also tells you about your rights under applicable privacy laws.

Table of Contents

  1. Introduction
  2. Changes to this Privacy Notice
  3. Information We Collect
  4. Using Your Personal Information
  5. Sharing Your Personal Information
  6. Marketing Communications
  7. Your Choices
  8. Children’s Privacy
  9. Payment Processing
  10. App Store Data and External Websites
  11. Data Retention
  12. Data Security and Protection
  13. Notice to Users Located Outside the United States
  14. Contact Us

1. Introduction

ClinIQ, Inc., a Delaware corporation (collectively, “ClinIQ”, “we”, “us” or “our”), provides the VirusIQ mobile application (the “App”) that provides users with informational resources regarding certain viral illnesses, including, without limitation, prevention and exposure information (the “Service”). This Privacy Notice is intended to help you better understand how we process your personal information, and governs how ClinIQ may use, transfer, store and disclose such personal information.
“Personal information” or “personal data” means any information about an individual from which that person may be identified. For example, it may include your name, telephone number, email address, or payment information, and in some jurisdictions your IP address. It does not include data from which the identity of an individual has been definitively removed along with any identifiers connected to such individual (also known as anonymous or anonymized data).
ClinIQ may collect personal information when you:
  • Download and/or use the App
  • Access and/or use the Service
  • Make purchases through the App and/or Service
  • Interact with and/or use support and other services provided by us as part of or in connection with the App and/or Service
  • Communicate with us directly.
When we refer to the “Services” throughout this Privacy Notice, we mean the App and Service, and any other services provided by us to you in connection with the App and/Service.
BY ACCESSING OR USING OUR SERVICES, OR SUBMITTING INFORMATION IN CONNECTION WITH YOUR USE OF THE SERVICES, YOU ACKNOWLEDGE AND AGREE THAT YOU HAVE READ THIS PRIVACY NOTICE.

2. Changes to this Privacy Notice

ClinIQ reserves the right to update or modify this Privacy Notice at any time. The revised Privacy Notice will be posted on the web page www.virusIQ.health. All updates and modifications to Privacy Notice will be effective from the day they are posted online (except as stated below). If we make any material changes to Privacy Notice, we will notify you of these changes by posting a notice of the changes on our website located at www.virusIQ.health (the “Site”) and through the user interface of the App, and we may send you a text message and/or email to your number or email address, as applicable, that we have on file for you. It is your responsibility to regularly visit and review Privacy Notice. If you do not agree to any updates or modifications to Privacy Notice, simply do not use or access the App and/or Service. Your continued use of the App and/or Service after we have posted the updated Privacy Notice, or, in the event of material changes, ten (10) days following the date we posted the notice of such changes on the Site and/or the App, as applicable, signifies to us that you acknowledge and agree to be bound by the revised Privacy Notice.

3. Information we Collect

a. Information Collected Directly

In connection with you use of the Services, ClinIQ may collect the following personal information directly from you:

  • Your identity, including your first name and last name
  • Government-issued ID
  • Your username, password and/or other login credentials
  • Your employer and/or employment information
  • Your recent travel history
  • Pictures of your face
  • Voice recordings
  • Certain health information, including, without limitation, current symptoms and detailed medical history
  • Your current and/or recent location(s) (which may include the city and/or zip code)
  • Your contact details, including your email address, phone number and/or postal address
  • Contact information of individuals who you have recently been in contact with, including their name, email, phone number and/or postal address
  • Other information you may provide by filling out forms or by contacting us (such as your feedback or other communications with us).

IMPORTANT – PLEASE NOTE if you provide personal data to us about someone else, you must ensure that you have the right to disclose that information to us and that the individual concerned is aware of the terms detailed in this Privacy Notice. We will collect, use and disclose such information as described in this Privacy Notice.

In addition, please be advised that we may ask you to update your information from time to time in order to keep it accurate.

b. Sensitive Data

ClinIQ collects the following sensitive information in connection with your use of the Services: your race and/or ethnicity, sex life, and information about your health, which may include genetic and/or biometric data.

Except for the data expressly described above, ClinIQ does not require you to provide any sensitive data about your religious or philosophical beliefs, sexual orientation, political opinions, or trade union membership information to use the Services.

c. Information Collected Indirectly

Geolocation Information

Certain features and functionalities of the App are based on your location. In order to provide these features and functionalities while you are using your mobile device, we may, with your consent, automatically collect geolocational information from your mobile device or wireless carrier and/or certain third-party service providers (collectively, “Geolocational Information”). Collection of such Geolocational Information occurs only when the App is running on your device. You may decline to allow us to collect such Geolocational Information, in which case we will not be able to provide certain features or functionalities to you.

Usage Information

When you use or interact with the Services we, or our authorized third-party service providers, automatically collect information about how you use them (collectively, “Usage Information”).

Usage Information that we collect consists of information about your interactions with the Services, including information about the device used by you to interact with and/or access the Services, including, without limitation, IP address, access dates and times, information about your approximate location (as determined through your IP address), mobile device information, device event information, crash data, and log data when you access and use the Services.

This information allows ClinIQ to understand how you’ve used the Services (which may include administrative and support communications with us or whether you have clicked on third-party links), and other actions you have taken in connection with your use of the Services. We use this information for our internal purposes, specifically to operate, maintain, secure and improve the Services. We may also use this information to provide you with notifications, recommendations, and information about specific features of the Services and/or additional products, services, or features we believe may be of interest to you.

Cookies and Similar Technologies

We or authorized third parties collect certain information by automated means using cookies, web beacons, and server logs for analytic purposes. ClinIQ tracks users use of the Services, but does not track users across third party websites. A cookie is a small text file that is stored on a user's computer for record-keeping purposes. When you visit or access the Services, we may by means of cookies, beacons, tags, scripts, and/or similar technologies automatically collect technical information about the devices and software you use to access the Services, such as the type of Internet browser or mobile device you use, the website or source that linked or referred you to the Services, your IP address or device ID (or other persistent identifier that uniquely identifies your computer or mobile device on the Internet), the operating system of your computer or mobile device, and other similar technical information. Typically, all technical, analytics, and usage information is gathered by ClinIQ in anonymous form and does not identify you personally.

We use both session ID cookies and persistent cookies. These technologies (or a combination of them) are used to help us:

  • Compile statistics and analytics about your use of and interaction with the Services, including details about how and where our Services are accessed, how often you visit or use the Services, the date and time of your visits, your actions on the Services, and information regarding in-App activities, and other similar traffic, usage, and trend data, which allow us to better understand the functionality of our mobile software on your device and gain insights about how mobile software is used in order to improve your experience
  • Gather important functionality, testing, and performance data about our Services, including performance data related to the App, such as networking activity, CPU load, and resource usage, among other relevant data
  • Moderate user behavior on the Services, such as protecting against fraud and other inappropriate activities
  • Gather demographic information about our user base
  • Perform other similar functions.

We may use third party tools and technologies to help us gather this information discussed above. For instance, we use Fabric and Firebase, products provided by Google, Inc., which includes, Google Analytics to collect and process certain analytics data with technologies such as tracking pixels.

Google provides some additional privacy options described at www.google.com/policies/privacy/partners/ with respect to Google Analytics cookies. To opt out from Google Analytics, you can download a plug-in from http://tools.google.com/dlpage/gaoptout.

d. Information Collected from Third Parties

In some instances, we process personal information from third parties, which consists of:

  • Data from our partners, such as transactional data from providers of payment services
  • Data from existing users who list you as a person with whom they have been in contact with
  • Data from existing users who list you as a family member, emergency contact and/or physician.
e. Aggregated Data

With the personal information and other data (including, Usage Information) collected by us, we process “Aggregated Data”, such as statistical or demographic data. Aggregated Data may be derived from personal information, but is not considered personal information under the law if it does not directly or indirectly reveal your identity. For example, we may aggregate usage data to calculate the percentage of users accessing a specific feature of the Sites and/or Service, or provide Aggregated Data to researchers or health organizations. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information, which will be processed in accordance with this Privacy Notice.

4. Using Your Personal Information

Depending on the Services requested by you and how you use those Services, we use your personal information in the following instances:

  • To perform and provide the Services to you, including, without limitation, to analyze certain health information to provide you information for your use to assess your risk of exposure
  • Facial scans are promptly analyzed by our algorithms to create a digitized temperature map that does not contain your facial features (we do not use facial scans for identification or authentication purposes)
  • Voice recordings are promptly digitized and analyzed for respiratory readings (we do not use voice recordings for identification or authentication purposes);
  • To refer our Services to individuals you have been in recent contact with;
  • To invite your selected family members and/or physician to access the Service that you have requested;
  • Conduct statistical analyses and train our algorithms;
  • Deliver direct marketing communications to you regarding our products and services that we may think are of interest to you;
  • Respond to your queries and requests, or otherwise communicate directly with you;
  • Detect any fraudulent or illegal activity against you and/or ClinIQ;
  • Perform system maintenance and upgrades, and enable new features;
  • To comply with a legal or regulatory obligation (for example, keeping records of our sales for tax compliance); and
  • Provide information to regulatory bodies when legally required, and only as outlined below in Legal Obligations and Security.

5. Sharing Your Personal Information

Aside from disclosing your information to those of our personnel who are authorized to process the information in order to provide the Services and who are committed to confidentiality, we disclose your personal information only to the third parties as described below.

a. Third-Party Service Providers

We share personal information with third parties that provide services to help us provide the Services, and to otherwise operate our business. Depending on how you use the Services, the following categories of third parties collect data on our behalf or receive personal information:

  • Hosting services providers;
  • Analytics providers;
  • Advertising and marketing partners;
  • Payment service providers;
  • Customer support providers;
  • Providers of business operations and communication tools;
  • Other third-party service providers that help us provide features and functions for the Services; and
  • Professional service providers, such as auditors, lawyers, consultants, accountants and insurers.

For a list of all third-party service providers we use, please contact us. We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions, unless the data is rendered fully anonymous.

b. To Third Parties at Your Request

If you request to share your information with family members, physicians and/or other third parties through the Service, we will share your information with such third parties. In addition, in the future, with your explicit consent, we may share your personal information with local health organizations and/or the Center for Disease Control and/or airlines you have recently traveled with.

Note that the third parties with whom you choose to share your information (as described in the immediately preceding paragraph) are not our service providers, and if you choose to share your information with those third parties, they may use your personal information differently than we do, and we do not control their use of your information. Please make your choice to share your information carefully and review the privacy notices of all other third parties you decide to share your information with, if applicable.

ClinIQ will not be able to contain or retrieve personal information once it has been shared or disclosed, and ClinIQ will have no responsibility or liability for any consequences that may result because you have released or shared personal information with others.

c. Business Transfers

We may also share data with third parties to whom we choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Privacy Notice.

d. Affiliates and Subsidiaries

Personal information that we collect about you through the Services may be shared with the employees, contractors, and agents of ClinIQ and our affiliated and subsidiary entities (“Affiliates”) who are involved in providing or improving the Services that we offer to you. We obligate the employees, contractors and agents of ClinIQ and our Affiliates to ensure the security and confidentiality of your personal information and to act on that personal information only in a manner consistent with this Privacy Notice.

e. Legal Obligations and Security

If we are required to disclose personal information by law, such as pursuant to a subpoena, warrant or other judicial or administrative order, our policy is to respond to requests that are properly issued by law enforcement within the United States. Under such circumstances, we will attempt to provide you with prior notice that a request for your information has been made in order to give you an opportunity to object to the disclosure. We will attempt to provide this notice by email, if you have given us an email address. However, government requests may include a court-granted non-disclosure order, which prohibits us from giving notice to the affected individual. In cases where we receive a non-disclosure order, we notify the user when it has expired or once we are authorized to do so.

Note that if we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person, we may provide information to law enforcement trying to prevent or mitigate the danger (if we have it), to be determined on a case-by-case basis.

6. Marketing Communications

If you have not otherwise opted out, or if you have opted in to receive direct marketing emails from us, we may use your personal information to send you marketing information about the Services, other ClinIQ products and services, new product releases, and new feature releases of the Services that we think may interest you. We carry out direct marketing by email.

If you no longer wish to receive marketing communications, you have the right at any time to opt out as further explained in Your Choices.

7. Your Choices

Updating and Correcting Personal information

If you would like to correct or update certain personal information (such as your contact information) please contact us at accounts@cliniq.health and we will use reasonably efforts to correct and/or update such information. Other information, such as health information provided in connection with a risk assessment entry, may not be modified once you have completed and logged the entry through the Service; however, you may update such entries by completing a new risk assessment entry, which will may be logged as a new version of the previous through the Service.

Direct Marketing

You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing e-mails. We will use commercially reasonable efforts to process such requests in a timely manner. You cannot opt out of receiving transactional e-mails related to the Services (e.g., requests for support).

Cookies

With respect to your choices regarding cookie and other tracking technologies, most web and mobile device browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browsers or mobile devices. Please note, however, that by blocking or deleting cookies used on the Services, you may not be able to take full advantage of the Services.

ClinIQ does not process or respond to web browsers' "do not track" signals or other similar transmissions that indicate a request to disable online tracking of users who use our Services.

8. Children’s Privacy

ClinIQ does not target the its Services to persons under the age of 13 and does not knowingly collect personal information from minors. Therefore, we ask you not to provide us with personal information of persons under the age of 13. If we learn that personal information of persons under 13 years of age has been collected on or through the Services, then we may deactivate the account or otherwise terminate access to the Services and/or make the user content inaccessible.

9. Payment Processing

We do not directly collect your payment information and we do not store your payment information. We use third-party, PCI-compliant, payment processors, which collect payment information on our behalf in order to complete transactions. Our administrators are only able to view limited transaction information via our payment processors’ portals

10. App Stores and External Websites

Your app store (e.g., iTunes or Google Play) may collect certain information in connection with your use of the App, including, without limitation, personal information, geolocational information, and other usage-based data. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies.

On or through the Services, we may provide or make available, for informational purposes only, links to other websites or resources with which we do not have a contractual relationship and over which we do not have control (“External Websites”). Such links are not paid advertisements, nor do they constitute an endorsement by ClinIQ of those External Websites, and are provided to you only as a convenience. By clicking on links to External Websites, the operators of the External Websites may collect your personal information. We are not responsible for the content or data collection practices of those External Websites, and your use of External Websites is subject to their respective terms of use and privacy policies.

11. Data Retention

Your personal information is processed for the period necessary to fulfill the purposes for which it is collected, to comply with legal and regulatory obligations and for the duration of any period necessary to establish, exercise or defend any legal rights.

In order to determine the most appropriate retention periods for your personal information, we consider the amount, nature and sensitivity of your information, the reasons for which we collect and process your personal information, and applicable legal requirements.

In some instances, we may choose to anonymize your personal information instead of deleting it, for statistical use, for instance. When we choose to anonymize, we make sure that there is no way that the personal information can be linked back to you or any specific user.

12. Data Security and Protection

We have put in place reasonable and appropriate security measures designed to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. For example, we use encryption, secure socket layer, firewalls, and password protection. In addition, we require two-factor authentication for all employees and contractors who may access your data to provide our Services, and we limit access to those employees, agents, contractors and the third parties who have a business need-to-know.

With respect to Sensitive Information, our practices include, but are not limited to the following:

  • Encryption. ClinIQ uses industry standard security measures to encrypt Sensitive Information both when it is stored and when it is being transmitted.
  • Limited Access. We limit access of Sensitive Information to authorized personnel, based on job function and role. ClinIQ access controls include multi-factor authentication, single sign-on, and a strict least-privileged authorization policy.

We also have procedures in place to deal with any suspected data security breach.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and while we take reasonable steps to provide secure Services, by using the Services, you understand and assume the risks associated with your activities on the internet.

In addition, you have responsibility and control over protecting your personal information. For example, you, and not ClinIQ is responsible for safeguarding your password, and other authentication information you use to access our Services. You should not disclose your authentication information to any third party and should immediately notify ClinIQ of any unauthorized use of your password.

In addition, as described in this Privacy Notice, ClinIQ cannot secure, and has no responsibility for, any personal information that you share or release on your own or that you request us to share or release.

13. Notice to Users Outside the United States

The Services and its servers are operated in the United States. If you are located outside of the United States, please be aware that your information, including your personal data, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Services, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

14. Contact Us

If you have any questions about this Privacy Notice, have additional questions, please contact us by email at: accounts@cliniq.health; or by mail at:
ClinIQ, Inc.
8 The Green, STE R
Dover, Delaware, USA 19901
Attn: Privacy Officer

♥ 2020 CLINIQ, INC. ALL RIGHTS RESERVED.